MiCA is now in force. Here's what that means for your crypto payments

Today, the EU's Markets in Crypto-Assets regulation (MiCA) came into full force, and the transitional “grandfathering” period that let crypto firms keep operating while they applied for licences has officially closed.

After today, there are two kinds of crypto payment providers in Europe: those that are fully regulated and licensed, and those that can no longer legally serve European customers.

If you use crypto payments in your business, for settlement, payouts, subscriptions, or treasury, this matters to you regardless of where your business is based.

What MiCA actually requires

MiCA is the EU's comprehensive regulatory framework for crypto-assets. For payment providers, the critical requirement is a Crypto-Asset Service Provider (CASP) licence, issued by a national competent authority within the EU.

A CASP licence authorises a firm to provide crypto-asset services, including the custody, exchange, and transfer of crypto-assets, to clients within the EEA. Under MiCA's passporting rules, a CASP licence obtained in one EU member state lets a provider operate across all 30 EEA states without additional national licences.

Payment providers involved in payment initiation and settlement, as most stablecoin payment processors are, also need a Payment Institution (PI) licence alongside the CASP authorisation. The two licences cover different regulatory ground: the MiCA licence covers crypto-asset service, and the PI licence covers payment services. Operating recurring billing or settlement flows without both is a material compliance gap. Confirmo is one of the few dual-licensed providers (CASP and Payment Institution), regulated by the Central Bank of Ireland.

Industries most directly affected include payment processors, fintech platforms, exchanges, stablecoin issuers, PSPs serving EU merchants, prop trading platforms, and any business that routes customer payments through crypto infrastructure serving EEA customers.

The scale of what has just happened

The numbers tell the story clearly. In 2024, more than 3,000 crypto firms held national VASP registrations across the EU, the legacy regime that let them operate during the transition period. According to an analysis by law firm Hogan Lovells, around 75 percent of those firms are expected to lose their registration as today's deadline passes. As of now, 194 providers hold full MiCA authorisation.

This is not a theoretical risk. Since MiCA's stablecoin rules came into force in December 2024, major EU-regulated exchanges have already restricted or removed coins whose issuers lacked authorisation. Now, the same logic applies to the providers processing those payments: without a CASP licence, they must stop serving European customers. Firms that knew they would not make it through the authorisation process were already preparing orderly wind-down plans.

Derek Corcoran, CEO of Confirmo’s Irish entity, put it directly:

"MiCA's grandfathering window has closed, so from now on, there are two kinds of crypto payment providers in Europe: those that are fully regulated and licensed, and those that can no longer serve European customers."

What this means for businesses using crypto payments

If there is any uncertainty about your provider's authorisation status, that uncertainty is now a material operational risk. Contracts, settlement flows, and reconciliation processes built on an unlicensed provider are all exposed, not to a future enforcement action, but to an immediate obligation on the provider's part to cease serving your business.

The questions to ask your provider today are simple. Do you hold a MiCA CASP authorisation? Do you hold a Payment Institution licence? Can you provide the licence numbers for verification on the ESMA register? A provider that cannot answer these questions with specifics is not authorised.

MiCA's reach beyond Europe

A common misconception, particularly among US-based businesses, is that MiCA does not apply to them. It does.

MiCA jurisdiction follows the customer, not the merchant or the provider. If any of your subscribers, clients, or end users are EU or EEA residents, your payment infrastructure is subject to MiCA requirements regardless of where your company is incorporated or where your provider is headquartered.

This is also why MiCA matters for US stablecoin issuers operating internationally. MiCA classifies fiat-referenced stablecoins as E-Money Tokens (EMTs) and requires their issuers to hold Electronic Money Institution authorisation under the regulation.

Stablecoins issued by firms without that authorisation may no longer be offered as a regulated payment option to EEA customers through MiCA-authorised infrastructure — which constrains how a US issuer can distribute those coins through regulated European channels.

Regulators globally have been watching MiCA closely. The US GENIUS Act, signed into law in 2025, draws on many of the same foundational principles: reserve requirements, redemption rights, AML standards. As Derek Corcoran noted:

"MiCA was the first regulation of its kind, and it has set a global standard you can already see other regulators drawing on."

What happens next

The immediate effect is consolidation. The providers that invested in authorisation, a process that takes six to twelve months, requires significant capital, and demands robust AML, Compliance governance, and operational frameworks, now operate with a structural advantage.

Derek Corcoran continued:

"The market will now consolidate around the providers that took compliance seriously, as quality of regulation becomes a genuine competitive advantage. Compliance teams will ask harder questions of their payment partners and the answers will matter more than before."

For businesses on compliant infrastructure, the opportunity is real. Faster and more cost-effective settlement across payments, FX and treasury flows, and the confidence to scale on rails that regulators have verified are no longer aspirational. They are the baseline for operating in European markets.

How to verify your provider's MiCA status

Check the ESMA register of authorised crypto-asset service providers. Ask your provider for their CASP licence number and their Payment Institution licence reference. Both should be verifiable in under five minutes.

Confirmo is authorised by the Central Bank of Ireland as a MiCA Crypto-Asset Service Provider and as a Payment Institution (Institution Code C570624). Our dual authorisation lets us passport services across all 30 EEA states from a single regulatory base, with no jurisdictional gaps and no re-licensing requirements.

If you are reviewing your crypto payments infrastructure in light of today's deadline, we are available to optimise your setup.

Confirmo Limited is authorised by the Central Bank of Ireland as a Crypto-Asset Service Provider under MiCA and as a Payment Institution under the Payment Services Regulations 2018 (Institution Code C570624).